Data Policy

What personal data are we likely to collect?
• Personal identification and communication information: your name, home address, phone number; email address; date of birth, gender, immigration status, and information about your entitlement to work;
• Application-related information: curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, position preferences, willingness to relocate, desired salary, interests and aspirations, and background screening information if relevant;
• Sensitive information: information about your health and disabilities where we need to make any reasonable adjustments, where you have volunteered such information to us, where otherwise required for equal opportunities monitoring (which may include information about your ethnic origin, sexual orientation, health and religion or belief); and
• Financial information: banking information in order to enable our third-party payment processor to reimburse you for expenses incurred in the application process.

We collect most of this information from you directly. E.g., data is collected through our application portal and/or CVs; from correspondence with you; or through interviews, meetings or other assessments. We may also collect some information about you from other people (e.g., recruiters, referrals), your referees or organizations (e.g., from LinkedIn), and where applicable, we may also collect data from our third-party background screening provider (during the pre-employment/internship screening process).
3. Why do we collect, use and store this personal data?

We collect, use and store your personal data for the reasons set out below.
• Where necessary for EAGLE ENTERPRISES to take steps prior to potentially entering into an employment/internship contract with you:
o To make informed decisions on recruitment and assess your suitability for the role;
o To communicating with you about your application, to respond to your inquiries and to schedule interviews; and/or
o To reimburse you for any agreed expenses incurred in the application process where applicable.
• Where necessary for EAGLE ENTERPRISES’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights. For example:
o To improve our internship and/or recruitment process and activities;
o To verify the details you have supplied and, where applicable, conduct pre-employment/internship background checks;
o To protect our legitimate business interests and legal rights, including, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements; and/or
o To analyze and monitor the diversity of the workforce in accordance with applicable laws. This includes, e.g., compliance with equal opportunity employment laws.
• Where necessary to comply with a legal obligation. For example:
o To assess your fitness and propriety in connection with your engagement in a controlled function, where applicable; and/or
o To comply with legal, regulatory and other requirements under applicable laws.
• Where you have given consent. For example:
o To contact you about future career opportunities at EAGLE ENTERPRISES.
4. Verification and background checks

For certain positions, it will be necessary for us to verify the details you have supplied (e.g., in relation to your identity, employment history, academic qualification and professional credentials) and to conduct pre-employment/internship background checks (e.g., in relation to previous criminal convictions or financial standing). The level of checks will depend on your role, in particular whether you will occupy a regulated role, and will be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and will obtain any necessary consents or acknowledgements prior to completing such checks.

5. How do we share your personal data?
Personal data will primarily be “processed” (used in this document as defined under the GDPR) by employees in our People, Talent, IT, Finance, and Facilities teams across our group of companies. If you are applying for a position from outside of the USA, this may therefore include sharing your personal data with our affiliates in the USA and in other jurisdictions.

Your personal data will also be shared with companies providing services, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies, under contract to EAGLE ENTERPRISES as part of the recruitment process. For general recruitment services, we use a third-party candidate tracking system. We may also share your personal data with other third-party service providers (e.g., providers of background checks). Your personal data will also be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws. In the event that a EAGLE ENTERPRISES business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

In the event that your personal data is otherwise transferred outside of the European Union/UK to an organization (including one of our affiliates) in a country which is not subject to an adequacy decision by the European Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected e.g., by way European Commission approved Standard Contractual Clauses, or by relying on such other data transfer mechanisms as available under applicable data protection laws.

We decided to self-certify under the Privacy Shield Framework but we also have entered into European Commission approved Standard Contractual Clauses to provide adequate protection for such transfer in the event the Privacy Shield Framework is invalidated as a transfer mechanism. You may request additional information in respect of such transfer mechanism by exercising your rights as set out below. Otherwise, please note that the Privacy Shield Framework was developed specifically to establish a way for companies to comply with data protection requirements when transferring personal data from the European Union/UK to the United States.

Updates to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
9. Contact us
The “data controller” (as defined under the GDPR) for your personal data will be EAGLE ENTERPRISES. If you have any questions regarding our privacy practices or would like to review or update your personal data, you may email us at privacy@EAGLE You can also contact us by writing to us at the following address:
EAGLE ENTERPRISES. Attention: Legal Department – Privacy Issues 310 Stone Valley Circle, Sacramento CA 95823